The changes are not accompanied by any written explanation or justification, so the following is based on our own analysis.
Changes Proposed to February 2021 application
Lower Ground Floor:
42 space cycle store moved to upper ground floor. Reconfiguration of service core. Minor changes to the sizes of the seven flats. Changes to windows in flat EB-02.
Upper Ground Floor:
Instead of 5 x 1 bed and 1 x 2 bed flats, there are now 3 x 1 bed and 2 x 2 bed flats. Changes to size of flats. Bike storage is now inside the building – through two doors. Reconfiguration of service core. Minor changes to size of flats.
First, Second and Thrid Floors:
Minor changes to size of flats. Changes to configuration of windows including orial windows on northern facade replaced with standard window.
New tiled mansard roof over service core. Cast stone copings to edges.
Grey brick replaced with red brick and buff brick. Aluminium coping replaced with cast stone. Changes to configuration and size of some windows. Slight reduction in roof height although this isn’t consistent between drawings. Juliet balconies removed on north elevation and orial windows replaced with standard.
Concerns not addressed:
While the grey bricks have now gone many of the other concerns about the proposals that we and others raised, including at last February’s community meeting, remain unaddressed. These include the low levels of natural light in lower ground and ground floor flats, the lack of natural surveillance in the sunken courtyard, impact on amenity on neighbours, and inconsistencies regarding green roof or PVs. Click here to see our full objection on the Council’s website.
The Carriageworks Action Group has today submitted an objection to the planning application to build 28 1 and 2 bedroom flats on the site currently proposed for eight 3 and 4 bedroom houses. This hasn’t been an easy objection to make as we support the broad priniciple of more social and affordable housing on the site. However, the quality of the proposals is so far below acceptable standards we feel we have to object. The content of the objection is below.
Objection to 21-00577-F
In December 2011 the Carriageworks Action Group produced its Community Vision for the future of the Carriageworks. This built on extensive public debate and consultation and was later adopted by Bristol City Council. Excerpts from the Community Vision that are relevant to this application are as follows:
“We want to see a true mix of housing types for sale and for rent including private and social housing, both low and high cost; a range of sizes should be provided to suit a mix of needs, from single people to families“.
“We want the new development to be designed to a high quality with good environmental standards. We want to see full use being made of roofs to provide opportunities for biodiversity and the creation of gardens, perhaps for growing food“.
The statement of community involvement that has been submitted by PG Group as part of the application rightly notes that CAG and others in the community have always wanted more social and affordable housing on the site than provided for in the approved 2015 scheme. When PG Group suggested, confidentially, to members of the Liaison Group* that this could be achieved by changing blocks E and F, in principle support was voiced.
On 14th December 2020 Liaison Group members were sent some plans for changes to Blocks E and F. We had substantial concerns, not least unit sizes below the national standards, and sent these to PG Group on 22 December. There was no further contact until after the planning application was submitted at the end of January. Neither did PG Group do anything to consult more widely with the local community about their proposed application.
CAG held a community meeting, via Zoom and attended by 18 people from CAG, on 25 February to discuss the application. PG’s architect presented the proposals and two other members of the PG team were able to provide answers to some of the questions posed.
Our objections to the proposals have, at their root, the divergence from the Community Vision in terms of unit size, occupation types and quality. While we remain committed to seeing more social and affordable units on the site this planning application fails on so many levels that we cannot support it. In particular:
The quality of residential space, in particular natural lighting of the interior and solar gain, is potentially below acceptable standards especially on the ground and lower ground floors. This is due to the lower ground levels, the presence of retaining walls and the height of the surrounding buildings. This will not only have an impact on the health of residents but will also put increased dependence upon artificial lighting and heating. A daylight assessment in accordance with BRE guidelines should be submitted
The proposals further consolidate a narrow mix of unit size on the site with the addition of more one bedroom units and the removal of larger units
The choice of external finish and material colours is depressing and more fitting to brutalist housing development in the Eastern Bloc. A more appropriate solution should be found that fits better with the local context
The lack of natural surveillance in the sunken courtyard gives us concerns about community safety. The advice of secure by design specialists should be sought
The increased height, the removal of the gap between Blocks E and F, the changed roof configuration, the placement of windows (in habitable rooms and corridors) and the materials used lead us to believe that there will be an increased impact on the amenity of neighbouring residential properties especially through the loss of natural light and overlooking. A daylight assessment and shadow path should be submitted along with sections showing the proposed building in the context of properties on the neighbouring streets
The impact of the increased height and depth of the building, compared to the permissioned Blocks E and F, is not justified by any benefit to the quality of design and the mix of unit size as aspired to by the Community Vision
Conflicting descriptions of the tenure mix have been provided. Most recently, at the February community meeting, we have even been told that the mix is unknown. It is impossible to support this application without knowing whether the scheme is for social rent, affordable rent or shared ownership occupiers
During site construction there has been almost constant Sunday working and working outside of permitted hours Mon-Sat, to the great detriment of local residents. If, as and when planning permission is granted there should be an absolute condition to prevent out of hours and Sunday working
The loss of green space, replaced in part by a dark subterranean courtyard
The amended parking layout needs a swept path analysis to demonstrate it is workable
The Energy and Sustainability Study states that PV panels cannot be installed because “the roof space for Block E is proposed to accommodate a green roof in the interest of biodiversity” (page 21). However, no green roof appears in the planning application drawings. There should either be PVs or a green roof.
In conclusion, the proposed development is unacceptable and would provide housing units that are unliveable. To refer back to a quote from a member of the planning committee when the first 2015 application was submitted: “Only its mother could love this”. Since 2015 we have come a long way but we are in danger of the scheme sliding backwards little by little, justified by challenging circumstances and the smoke and mirrors of viability. A mixture of unit sizes and occupation along with high quality design and environments is essential for this development to be a success. As they stand the fundamentals of this proposal are sub-standard and no amount of change to the exterior design will compensate. This is an important gateway site with a facade of historical importance both locally and nationally. From a potential silk purse PG have made a sow’s ear. These proposals should be referred back for improvement.
* The CAG Liaison Group comprises six people involved in CAG who engage at a detailed level with the developer and the Council to champion the Community Vision. They report back to the broader CAG community.
Andrew McCarthy from Stride Treglown (the project architects) summarised the new planning application and the reasoning behind them:
Site levels are 3m lower than those cited in the original planning application. So an extra storey of height
Review of best type of housing on site – preference for more social / affordable flats rather than private 4 bed houses
New block will have a footprint largely the same as the previous scheme although courtyard is slightly smaller due to extended frontage
Access is unchanged and parking is reconfigured
New lower level courtyard
Tried to keep same amount of green space and trees
Doors of flats open onto the courtyard to keep an active frontage
Orientation of rooms and windows to reduce overlooking of neighbours
Contrasting tone in the brickwork to keep sense of two parts to the block and to better address the change in window and door orientation between the different storeys.
Overall height of south wing is slightly lower than currently proposed houses
Units will be managed by Sovereign Housing Association.
Would like to see long sections to better understand how it relates to neighbouring properties outside the site
Concern about quality of living accommodation on ground and lower ground floors given the proximity of retaining walls and the lack of natural daylight. Do they meet minimum light standards? Hard to visualise what the lower ground floor flats will be like. They do not feel like attractive places to live. Just because they are affordable does not justify them being dark. Would not want to live there.
The overall density of development on the site will be too high with these additional units
What is the tenure mix?
Will there be a management fee on top of the rent?
Concern re security in the sunken courtyard due to lack natural surveillance. Need input from secure by design people
No playspace if there are children living on the site
If you start having children will you have to move out?
There is logic for contrasting brick colours, but a grey box is a cold brutalist style that does not fit well with Godwin. It will make neighbouring properties even darker than they currently are. Is there potential for a green wall? Different coloured brick? Tiles instead of brick?
Concerns about overlooking e.g. from corridor windows. Need obscured glazing
Bathrooms with external walls should have windows
Could lower and upper ground floors be combined to make duplex apartments – upper level would benefit from more light (although pointed out that even upper ground floor flats look directly at retaining walls at the rear)
There is demand for family housing in the area. Why can’t they be social/affordable family houses?
Does the parking layout work? There needs to be a swept path analysis
How bill bicycles be brought in?
Is the motivation the ground levels or making more profit?
What is the timeline
Response to comments from PG team
Some tones of grey can be quite warm, but nothing yet decided. Key thing is to have a contrasting colour.
Have to avoid cladding with fire risks
The flats will have a mix of affordable tenures but no decision as yet on the exact mix
Density is changing from 8 x 4 bed houses (up to 32 people) to 8 x 2 bed and 20 x 1 bed. This is not a significant increase
All meetings with CAG since 2017 have requested more social housing – PG will now deliver on that
Don’t know answer re management fees – that will be up to Sovereign
Bicycles will come in from the central courtyard down shallow steps with a bike ramp
Target will be to complete Block E at the same time as the rest of the scheme, so Q3 or Q4 in 2022
Other discussion regarding the proposals
Family housing was promoted by SPD10 (2006). Since then demand has changed, in part because of the bedroom tax (i.e. higher demand for smaller flats). BCC can help get more data on current housing need based on bidding patterns in the area
Concerns about the lack of parking. This is Bristol City Council policy for last eight years. Has always been contentious but is not something we (CAG) can resolve. Best for residents to lobby local councillors on this issue
How to apply for affordable housing? Have to apply via Bristol City Council
Is the Carriageworks frontage safe given the high winds of late? A: It is very secure – a lot of concrete holding it down and the steel frame now bolts onto the facade from the rear. Completion of the steel frame in 3-4 weeks time will enable the structural scaffolding to be removed and be replaced with access scaffolding to allow the large amount of cleaning and restoration to start.
PG Group have submitted a new planning application for Blocks E and F – the two blocks of houses at the rear of the site. Full details of the planning application can be found on the Council’s website. There will be a community meeting to discuss the proposals – see end of this post for details.
The proposal is to replace the 3 x 4 bed and 5 x 3 bed family sized houses (given planning permission in 2015), for which there is probably limited demand in this location, with a single block of 28 affordable flats.
The proposed flats will comprise 20 x 1 bed two person flats and 8 x 2 bed three person flats.
More affordable units will help meet local housing needs and is something that CAG and the community have been pushing for for a long time.
The final development will now comprise:
95 x 1 bed flats
35 x 2 bed flats
8 x 3 bed flats
Total 138 flats
Of which 38 (28%) will be affordable. There will be 25 x 1 bed affordable flats and 13 x 2 bed affordable flats.
The affordable flats will be managed by Sovereign Housing Association, along with the shared ownership units in Block D.
The CAG Liaison Group was shown early plans just before Christmas for a scheme comprising 19 social rent and 14 shared ownership flats. We submitted comments on these proposals at the time since when the scheme has been amended.
Details of the proposals are as follows:
Housing tenure: The existing 2015 planning permission was for 8 houses for market sale or rent. The proposed changes shown to us before Christmas comprised a mix of social rent and shared ownership flats. It is now for affordable shared ownership flats only. “Affordable” = 80% of market value.
Footprint: The two blocks are now merged into one ‘L’ shaped block. The footprint is slightly larger, mostly with the south west facade extending further towards the south west.
Height: At its highest point the building is now one storey higher than the 2015 permissioned scheme. There is also a new lower ground floor, although this does make use of the existing ground levels, which are 2.5m lower at this end of the site, whereas the permissioned scheme would require the ground level to be increased by the equivalent of one storey. Most of the building is therefore five stories in height, with the lower part four stories.
Massing: The merging of the two blocks with the loss of the gap in between, the greater height and the additional lower ground floor creates a larger mass than the permissioned scheme.
Daylight: No shadowing details have been provided, but the higher building will inevitably lead to increased shadowing, especially of the Brigstocke Road gardens. The lower ground floor flats will have limited natural daylight. The ground floor flats have rear windows looking directly at retaining walls.
Parking: As in the 2015 scheme, there are six spaces reserved for disabled drivers. The configuration has been changed which could result in them being blocked by other vehicles e.g. delivery vans. However, this situation was only marginally better in the 2015 scheme.
Security: While the pathway behind the building has restricted access there appears to be open access to the area around the lower ground floor which is largely hidden from observation. Also risk of tagging on the brick walls. Need comments from the Secure by Design team.
Materials and finishes: Buff and grey brick. This seems a rather austere choice.
Planting: The permissioned scheme included a pocket park in front of the houses and gardens to the rear. The pocket garden has been replaced by a sunken courtyard with planting and planting beds close to the parking. To the rear of some of the lower ground floor flats there are planted courtyards with crab apple and rowan trees. The lack of direct sunlight to the courtyard areas will limit the choice of plants. The sustainability statement states that the building will have a green roof, although this is not referred to elsewhere and is not shown in the roof plan.
Drainage: The application states that all surface water will be discharged through the main sewers. There is no provision for soak-aways. It is not immediately clear how surface run-off adjacent to Kuumba, which is the lowest point on the site, will be handled.
We will be holding a community Zoom meeting on Thursday 25 February 7-8pm. We’ve invited PG to present their proposals after which there will be a chance for questions. If you would like to take part in the meeting please contact us at email@example.com to request the Zoom link. If you have questions it will help us manage the meeting if you can submit them in advance using the same email address.
As anyone regularly passing or living close to Carriageworks will be aware, work above ground began late November and the steel work is quickly taking shape. PG Group, the developer, found some of the worst ground conditions they’ve ever encountered with large amounts of buried concrete, steel girders etc pointing to the site’s long industrial past.
COVID and Brexit have both been challenges for the development so far with impact on the supply of both labour and materials.
Block A (the largest of all the blocks but without a direct frontage to Stokes Croft) has now reached its finished height of six storeys, although roof finishes will add a bit to the final height.
The steelwork for Block D. behind Croft Dale, is also progressing.
Block C, the Carriageworks building itself, will be the last to be completed, probably by late 2022.
As part of PG Group’s efforts to get the Carriageworks development started they have submitted a new planning application.
Last year PG were focused on a S.73 minor alterations application to add seven additional units to the fourth and fifth floors of Block A and make other changes to the facade, stair wells etc. However, a recent case in the Court of Appeal (Finney v. Welsh Ministers, 2019) effectively closed the S.73 route for the additional units. Consequently PG will remove the extra flats from the S.73 application so that the rest of it can go through. And they have now put in a full planning application for the flats.
The application can be seen on the Council’s planning website. Neighbours will have received written notification and the public consultation period officially ends on 6 April.
The application seeks permission for 3 x 1 bed flats and 4 x 2 bed flats for market sale or rent. The design, footprint and floor area are the same as previously proposed in the S.73 application except that one two bed unit has been split into two one bed units. The fourth floor is set back 2.2m from the Ashley Rd frontage and the fifth floor is set back by 7.75m and clad in grey metal in order, say PG, to reduce their visibility and prominence from street level when compared to the lower floors which will be clad in brick.
Floors plans and elevations of the additional seven flats proposed for the fourth and fifth floors of Block A.
Top drawings show the elevations as proposed by S.73 application excluding additional flats (not yet granted planning permission). The lower drawings show the proposed additions to the fourth and fifth floors.
However, because of a recent change in case-law, S.73 cannot now be used to change the description of a development (e.g. a change to the number of units).
As a result PG are proceeding with an amended S.73 application which doesn’t involve any change to the number of units and instead focuses on the internal and facade changes. Later on they will submit a full planning application for the two extended floors/extensions to create the extra floorspace and flats.
We understand that the planners will try to process the revised S.73 so that deadlines set by funders can be met and the site development can progress.
PG have submitted amendments to their proposals for Block A (fronting Ashley Road). The full details can be found on the planning website.
Note that these only affect Block A and not any of the other buildings on the site. The listed Carriageworks building is not part of the proposed changes.
The proposals vary the 2015 planning permission. They affect only Block A (referred to as A1 and A2 in the planning permission). A Section 73 (minor material amendment) application to change the permission was submitted in May 2019. These latest proposals vary that S.73 application.
CAG has created the images below, showing on the lefthand side of the image the original (May 2019) application to amend with the latest proposals on the right. (Note that the lefthand side image says October 2018 – this is the month that they were first released).
The key difference to the original amendment is the greater setback of the fourth and fifth floors.
Changes to the entrance area and the configuration of ground floor servicing and retail units.
Small change to roof over entrance.
Windows facing Hepburn Road revert to original planning application. See drawing below for details.
Closeup of windows facing Hepburn Road. Glazing will point south west. Solid infill pointing south east towards Hepburn Road back gardens.
We have just this evening received from PG these proposed changes to the designs of Block A. We have the community meeting tomorrow (Wed 10th July 6:30pm at St Pauls Learning Centre) so wanted to get these drawings to you as soon as possible. We haven’t yet had a chance to look at them.
Click the images below to open a PDF in a new tab.